It’s Your Call September 2018

OSHA: What is the importance of a housekeeping schedule?

Exposure to bloodborne pathogens are ever present in clinical settings, and employees must be protected from contaminated surfaces such as cabinets, patient beds, floors, equipment, walls, light handles, etc.

OSHA regulation 1910.1030(d)(4)(ii) states: All equipment and environmental and working surfaces shall be cleaned and decontaminated after contact with blood or other potentially infectious materials.

1910.1030(d)(4)(ii)(A):  Contaminated work surfaces shall be decontaminated with an appropriate disinfectant after completion of procedures; immediately or as soon as feasible when surfaces are overtly contaminated or after any spill of blood or other potentially infectious materials; and at the end of the work shift if the surface may have become contaminated since the last cleaning.

Adhering to a routine housekeeping schedule is one of the best ways to keep employees healthy and safe.

HIPAA: Our office has a cleaning service.   Should they sign a business associate agreement?

According to Health & Human Services (HHS), janitorial services are not generally considered business associates because when they do not use or need PHI to perform janitorial duties.

If the cleaning service performs additional duties such as shredding or disposal of PHI, it is permissible under the Privacy Rule to treat them as part of the workforce.  Under this condition, the covered entity has direct control over the janitorial service associates and PHI disposal and shredding) should be performed on work premises.

Ultimately, if janitorial services are not classified as business associates or part of the workforce, the covered entity must secure PHI to avoid a breach scenario.